FEES & CHARGES LIST AS OF 10/30/2015

Transcription

1 FEES & CHARGES LIST AS OF 10/30/2015 SPL = Service Providers List VP = Variations Permited DISCLAIMER: This document contains proprietary information for Platinum Mortgage internal staff use only. All information and opinions contained in this document are to be used as a guide and not intended to be used as legal or regulatory advice. Information contained in this document is subject to change based on staff, investor, agency, outside counsel and/or CFPB guidance or revisions. Final determination of points & fees will be made by Platinum Mortgage prior to closing. Fee Description Paid To Paid By RegulatoryReference Origination Creditor Borrower A A 0% YES YES (b)(1)(i) includes all finance charges under (a) and (b) Origination Creditor Seller/Creditor A A 0% NO NO Excluded from (b)(1)(i) because not a finance charge since paid by seller Origination Broker Borrower A A 0% YES YES (b)(1)(i) includes all finance charges under (a) and (b) Origination Broker Seller A A 0% NO YES (b)(1)(ii) includes originator compensation not already included as a finance charge under (i). Comment 37(f)(1) - 2 indicates LP comp is not disclosed on the LE Broker Compensation/Fee (LP) Broker Creditor N/A A N/A NO YES (b)(1)(ii) includes originator compensation not already included as a finance charge under (i) Discount Creditor Borrower A A 0% YES CONDITIONAL Must meet (b)(1)(i)(E-F) requirements for exclusion up to 2 points Discount Creditor Seller A A 0% NO NO Excluded from (b)(1)(i) because not a finance charge since paid by seller Discount Broker BROKER NOT ALLOWED TO CHARGE DISCOUNT SINCE WOULD NOT BE BONA FIDE DU / LP Fee (AUS Fee) Broker NO LONGER ALLOWED TO BE CHARGED Underwriting Fee Creditor Borrower A A 0% YES YES (b)(1)(i) includes all finance charges under (a) and (b) Underwriting Fee Creditor Seller/Creditor A A 0% NO NO Excluded from (b)(1)(i) because not a finance charge since paid by seller TX Doc Prep Fee (b)(1)(iii) TX Doc Prep Fee affiliate Seller/Creditor B B 0% No NO (b)(1)(iii) Processing, Admin, Commitment) Creditor Borrower A A 0% YES YES (b)(1)(i) includes all finance charges under (a) and (b) Processing, Admin, Commitment) Creditor Seller/Creditor A A 0% NO NO Excluded from (b)(1)(i) because not a finance charge since paid by seller Processing, Admin, Commitment) Broker Borrower A A 0% YES YES (b)(1)(i) includes all finance charges under (a) and (b) Processing, Admin, Commitment) Broker Seller/Creditor A A 0% NO YES (b)(1)(ii) includes originator compensation not already included as a finance charge under (i) --non Excluded from QM/HOEPA per (b)(1)(i)(D) as bonafide fee-- Fees Charges List Page 1 of 7 Rev 10/30/2015

2 RegulatoryReference --non Excluded from (b)(1)(i) because not a finance charge since paid by seller/creditor-- affiliate Borrower B B 0% YES YES (b)(1)(i) includes all finance charges under (a) and (b)-- Excluded from (b)(1)(i) because not a finance charge since paid by seller-- Flood Cert (life of loan) Flood Cert (life of loan) Appraisal affiliate Borrower B B 0% YES YES affiliate Any B B 0% NO NO Appraisal Appraisal Credit Report Appraisal Reinspection Appraisal Reinspection creditor affiliate Borrower / Seller B B 0% NO YES QM/HC per (b)(1)(iii) because paid to affiliate of creditor creditor affiliate Creditor B B 0% NO NO Not included in QM/HC per cfpb commentary 32(b)(1)-2 regarding creditor paid charges affiliate Any B B 0% NO NO affiliate Any B B 0% NO NO creditor affiliate Borrower / Seller B B 0% NO YES QM/HC per (b)(1)(iii) because paid to affiliate of creditor Appraisal Reinspection creditor affiliate Creditor B B 0% NO NO Not included in QM/HC per cfpb commentary 32(b)(1)-2 regarding creditor paid charges PIW/AVM Fee Creditor Borrower B B 0% YES YES (b)(1)(i) includes all finance charges under (a) and (b) PIW/AVM Fee Creditor Seller/Creditor B B 0% NO NO Excluded from (b)(1)(i) because not a finance charge since paid by seller Interim Interest Creditor Borrower F F VP YES NO Excluded from QM/HOEPA per (b)(1)(i)(A) Interim Interest Creditor Seller/Creditor F F VP NO NO Excluded from QM/HOEPA per (b)(1)(i)(A) Fees Charges List Page 2 of 7 Rev 10/30/2015

3 RegulatoryReference Conventional Upfront Mortgage Insurance Any Borrower B B 0% YES YES per cfpb commentary, refundable premiums must meet certain pro-rata refundability criteria that existing insurers policies do not meet Conventional Upfront Mortgage Insurance Any Seller B B 0% NO NO Excluded from (b)(1)(i) because not a finance charge since paid by seller Conventional Lender Paid Mortgage Insurance (LMPI) Any Creditor N/A N/A N/A NO NO Excluded from (b)(1)(i) because not a finance charge since paid by creditor FHA UFMIP FHA UFMIP VA Funding Fee VA Funding Fee Upfront USDA Guarantee Fee Upfront USDA Guarantee Fee Hazard Insurance Any Any F F VP NO NO Excluded from (b)(1)(i) because not a finance charge Flood Insurance Any Any F F VP NO NO Excluded from (b)(1)(i) because not a finance charge Reserves for escrow account Creditor Any G G VP NO NO affiliate Any C C Excluded from (b)(1)(i) because not a finance charge. Note that any reserves escrow for USDA Fee is included in APR No SPL Given = 0% NO NO Excluded as pass-through fee not retained by creditor affiliate per (b)(1)(iii) broker affiliate Any C C 0% NO NO Excluded as pass-through fee not retained by creditor affiliate per (b)(1)(iii) creditor affiliate Borrower / Seller C C 0% NO YES QM/HC per (b)(1)(iii) because paid to affiliate of creditor creditor affiliate Creditor C C 0% NO NO Not included in QM/HC per cfpb commentary 32(b)(1)-2 regarding creditor paid charges affiliate Any H H VP NO NO Excluded as pass-through fee not retained by creditor affiliate per (b)(1)(iii) Fees Charges List Page 3 of 7 Rev 10/30/2015

4 RegulatoryReference broker affiliate Any H H VP NO NO Excluded as pass-through fee not retained by creditor affiliate per (b)(1)(iii) creditor affiliate Borrower / Seller H H VP NO YES QM/HC per (b)(1)(iii) because paid to affiliate of creditor creditor affiliate Creditor H H VP NO NO Not included in QM/HC per cfpb commentary 32(b)(1)-2 regarding creditor paid charges affiliate Any C C No SPL Given = 0% NO NO Excluded as pass-through fee not retained by creditor affiliate per (b)(1)(iii) broker affiliate Any C C 0% NO NO Excluded as pass-through fee not retained by creditor affiliate per (b)(1)(iii) creditor affiliate Buyer / Seller C C 0% NO YES QM/HC per (b)(1)(iii) because paid to affiliate of creditor creditor affiliate Creditor C C 0% NO NO Not included in QM/HC per cfpb commentary 32(b)(1)-2 regarding creditor paid charges Excluded from QM/HOEPA per (b)(1)(i)(D) as bonafide fee not retained by broker, affiliate Borrower C C No SPL Given = 0% YES NO creditor or affiliate of either. affiliate Seller/Creditor C C No SPL Given = 0% NO NO Excluded from QM/HOEPA because not a finance charge under (b)(1)(i) broker affiliate Borrower C C 0% YES YES Included per (b)(1)(i)(D) since broker affiliate broker affiliate Seller/Creditor C C 0% NO NO Excluded from (b)(1)(i) since not a finance charge since paid by seller/creditor affiliate Any C C No SPL Given = 0% NO NO Excluded as pass-through fee not retained by creditor affiliate per (b)(1)(iii). Must be for actual or legitimate expenses. Disguising closing fee under one of these labels would require inclusion in APR & Possibly HC/QM. Fees Charges List Page 4 of 7 Rev 10/30/2015

5 broker affiliate Any C C 0% NO NO creditor affiliate Buyer / Seller C C 0% NO YES RegulatoryReference Excluded as pass-through fee not retained by creditor affiliate per (b)(1)(iii). Must be for actual or legitimate expenses. Disguising closing fee under one of these labels would require inclusion in APR & Possibly HC/QM. QM/HC per (b)(1)(iii) because paid to affiliate of creditor. Must be for actual 3rd party or legitimate expenses. Disguising closing fee under one of these labels would require inclusion in APR & Possibly HC/QM. Government doc recording fees creditor affiliate Creditor C C 0% NO NO Not included in QM/HC per cfpb commentary 32(b)(1)-2 regarding creditor paid charges Excluded from QM/HOEPA per (b)(1)(i)(D) as bonafide fee not retained by broker, affiliate Borrower C C No SPL Given = 0% YES NO creditor or affiliate of either. affiliate Seller/Creditor C C No SPL Given = 0% NO NO Excluded from QM/HOEPA because not a finance charge under (b)(1)(i) broker affiliate Borrower C C 0% YES YES Included per (b)(1)(i)(D) since broker affiliate broker affiliate Seller/Creditor C C 0% NO NO Excluded from (b)(1)(i) since not a finance charge since paid by seller/creditor affiliate Borrower C C affiliate Seller/Creditor C C No SPL Given = 0% YES NO Excluded from QM/HOEPA per (b)(1)(i)(D) as bonafide fee not retained by broker, creditor or affiliate of either. No SPL Given = 0% NO NO Excluded from QM/HOEPA because not a finance charge under (b)(1)(i) broker affiliate Borrower C C 0% YES YES Included per (b)(1)(i)(D) since broker affiliate broker affiliate Seller/Creditor C C 0% NO NO Excluded from (b)(1)(i) since not a finance charge since paid by seller/creditor affiliate Any E E 10% NO NO Excluded from (b)(1)(i) because not a finance charge Fees Charges List Page 5 of 7 Rev 10/30/2015

6 Government transfer tax RegulatoryReference affiliate Any E E 0% NO NO Excluded from (b)(1)(i) because not a finance charge Pest Inspection, Septic Inspection, Well Inspection, Home Inspection (Not Required for Loan) affiliate Any H H VP NO NO to creditor affiliate Pest Inspection, Septic Inspection, Well Inspection, Home Inspection (Required for Loan) Survey (Not Required for Loan) Survey (Required for Loan) Prepaid Property Taxes affiliate Any C C No SPL Given = 0% NO NO to creditor affiliate to creditor affiliate. Note if required by lender, then is included in APR and HC/QM unless paid by seller/creditor. to creditor affiliate. Note if required by lender, then is included in APR and HC/QM unless paid by seller/creditor. affiliate Any H H VP NO* NO* affiliate Any C C No SPL Given = 0% NO* NO* affiliate Any F F VP NO NO Excluded from (b)(1)(i) because not a finance charge Creditor Payoffs creditor affiliate Borrower N/A K VP NO NO Excluded from (b)(1)(i) because not a finance charge Creditor Payoffs creditor or affiliate Borrower N/A K VP NO CONDITIONAL If payoff to creditor (or affiliate) includes prepayment penalty, then this prepayment penalty is included in QM pts & fees per (b)(1)(vi) Assessment Prorations Buyer/Seller Buyer/Seller N/A K or L VP NO NO Excluded from (b)(1)(i) because not a finance charge Realtor Fees & Commissions Realtor Buyer/Seller N/A H VP NO NO Excluded from (b)(1)(i) because not a finance charge GA GRMA Fee affiliate Any E E 0% NO NO Excluded from (b)(1)(i) because not a finance charge Contractor Invoices (Not Excluded from (b)(1)(i) because not a finance charge--must document for legitimate Required for Loan) affiliate Any N/A H VP NO NO repairs/expense with invoices Contractor Invoices (Required For Loan) affiliate Any N/A H No SPL Given = 0% NO NO Excluded from (b)(1)(i) because not a finance charge--must document for legitimate repairs/expense with invoices Verification Fees (i.e., Work#/Equifax/4506) Verification Fees (i.e., Work#/Equifax/4506) affiliate Seller/Creditor B B 0% No NO Fees Charges List Page 6 of 7 Rev 10/30/2015

7 Regulatory Reference Foreclosure Expenses payable to contractors and attorneys which are solely the responsibility of the seller for an REO sale transaction affiliate Seller N/A N/A N/A NO NO Excluded from (b)(1)(i) because not a finance charge--contract MUST CLEARLY INDICATE BUYER IS IN NO WAY CONTRACTUALLY RESPONSIBLE EVEN IF SELLER PAID NO CONCESSIONS TOWARDS BORROWER CLOSING COSTS. Condo Assoc Initiation/Assessment/Misc Fee affiliate Buyer/Seller H H N/A NO NO Excluded from (b)(1)(i) because not a finance charge Note: For credit report/appraisal fees, even though "paid to" grid references, may be paid to broker on HUD-1 to reimburse actual expense only with copy of invoice as long as not provided by affiliate. SPL = Service Providers List VP = Variations Permitted Fees Charges List Page 7 of 7 Rev 10/30/2015